What about ISO? What does it have to do with Section 508?

ISO 14289-1 (2012) is a set of "consensus standards" that would be "incorporated by reference" into the proposed revision/update for Section 508 (refer here). It is the formal name for PDF/UA.

ISO 14289-1 (2012), Document management applications — Electronic document file format enhancement for accessibility — Part 1: Use of ISO 32000-1 (PDF/UA-1), would be incorporated by reference at E205.1 and 602.3.1. This is an international standard for accessible portable document format (PDF) files. PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation, and validation of PDF content to ensure accessibility for people with disabilities who use assistive technology such as screen readers, screen magnifiers, joysticks and other assistive technologies to navigate and read content. This proposed standard is new to both the 508 Standards and the 255 Guidelines. It is offered as an option to WCAG 2.0 for accessible PDFs.

Need PDFs that are compliant with Section 508, PDF/UA and ISO? Need answers right now? Call Accessibility In Mind, 919-410-7408, or visit our website.

FAQ: What fonts are compliant with Section 508?

Question: What fonts can I use? I read where you can only use system fonts Calibri, Times, Trebushi etc. and I want to use a different font for a document.

Answer: This is a common question, one that is NOT addressed in Section 508 of the Rehabilitation Act of 1973, as amended in 1998. Here's the pertinent section, "web-based intranet and internet information and applications (1194.22, sub-sections a-p)" right here.  See anything about fonts???

The regulations are not specific; various agencies have created their own interpretations and requirements. In February of this year, the Access Board published their proposal to remedy this, called the "Proposed Information and Communication Technology (ICT) Standards and Guidelines". They state, "Incorporating these standards complies with the federal mandate—as set forth in the National Technology Transfer and Advancement Act of 1995 and OMB Circular A119—that agencies use voluntary consensus standards in their regulatory activities unless doing so would be legally impermissible or impractical." And they even get more specific about their lack of specifics: "the existing 508 Standards, which contain no referenced standards."

How about that for guidance?  The proposed standards do go a long way down the long road that is accessibility, when approved. Until then, common sense is the best "voluntary consensus standard".

HHS "recommends" those fonts, but not using them does NOT mean you aren't in compliance. (HHS checklist: "Does the document utilize recommended fonts (i.e., Times New Roman, Verdana, Arial, Tahoma, Helvetica, or Calibri)?") Even with HHS, failing that checkpoint doesn't mean non-compliance; what makes a document non-compliant is if it is inaccessible. Obviously, the criteria is accessibility. The regulation does not say you have to use any particular font.

Best practice is to see if your client has a checklist or any guidance regarding their interpretation of the regs, and of course, use a readable font. Probably a no-no on the wingdings.....

More information on Section 508: http://508compliantdocumentconversion.com/

Question: I'm new to Section 508 compliance- how does"remediation" change our documents?

This is a common question from our new clients. Often all they know about Section 508 is that there is a line-item in their deliverables contract stating that they must provide a "Section 508 compliant" PDF to complete the job.  The "remediated" document returned from the compliance service looks exactly like the document sent to them. How do we know we have a compliant document.

First off, there is NO certificate that is issued by any government agency certifying compliance. Your only proof of compliance is documentation that accompanies your accessible PDF.

 Luckily, you have found a reputable document remediation service, Accessibility In Mind, and you can rest easy.  When we complete any remediation we provide our clients with documentation of the work performed, which includes accessibility reports from one or more sources:

• Acrobat 11 full accessibility report: This is the first stop, a report that shows compliance in 32 of 32 categories, and proves technical compliance.
• PAC Accessibility Check: The PAC program provides a fast way to test the accessibility of PDF files. PAC supports both experts as well as end users conducting accessibility evaluations, and is based on the Matterhorn Protocol. Matterhorn was designed to foster adoption of PDF/UA by providing a set of 31 Checkpoints and 136 Failure Conditions that help software developers exchange detailed information on PDF/UA conformance and create software to make it easier for document authors to create fully accessible PDF files and forms.
• CommonLook by NetCentric Section 508 Reports: Common Look is considered the "gold standard" for accessibility reporting, and is recommended by Health & Human Services (HHS) and is generally accepted for all government contracts.

Additionally, all AIM documents are spot-checked using JAWS, the most popular screenreader developed for computer users whose vision loss prevents them from seeing screen content or navigating with a mouse. (The read-aloud feature in Adobe Reader and Acrobat is NOT a substitute for a dedicated reader.) All AIM-remediated documents passing CommonLook accessibility checks meet HHS specifications and are guaranteed compliant with Section 508.

News Flash: Section508.VA Document on Creating Accessible PDFs is not compliant with Section 508- go figure!!!

http://www.section508.va.gov/support/tutorials/pdf/Creating_Accessible_PDF_Tutorials_with_Acrobat_XI.pdf

Check it yourself, doesn't pass the most rudimentary technical check, let alone a "human" review.

Undue Burden: A Legal Issue for Section 508 Compliance

Agencies can apply an exception to section 508's requirement to provide accessible and compliant documents if the creation of a compliant version would cause "an undue burden." Undue burden is defined as a significant difficulty or expense. However, the definition is not precise and is open to interpretation. Undue burden is a legal issue. Your agency should not consider such an exception without consulting legal counsel.

To determine if the undue burden exception applies, an agency must consider and thoroughly document the difficulty and expense of compliance in relation to all agency resources available to the program or component for which the product is being acquired.

When an agency qualifies for an undue burden exception, section 508 still requires it to provide an alternative means for individuals with disabilities to access the information. This means that even if the document is not accessible, the information or data it provides must be available through an alternative means of access. For example, an agency might provide a plain text version of a document that is not otherwise accessible.

Accessible and Compliant Tables

Question: There are plenty of interpretations of the Section 508 regulations. How do I know my organization is creating accessible tables?

Answer: An Accessibility Forum with over 960 individuals from more than 600 companies, associations for people with disabilities, research and standards institutes, and government agencies from throughout the US and Canada created a "Quick Reference Guide", which lists every Section 508 provision, defines terms, explains the provision, and answers, "How can I tell if this provision is met?" It may not be the law of the land, but it is very unlikely that a judge would over-rule their interpretations with their own. Below is their guidance regarding tables; they refer to HTML, but the same holds true for PDFs. Note that 1194.22(g) specifies only that row and column headers be "identified"; in a PDF the means <TH> and <TD> tags applied appropriately. 1194.22(h) deals with what may may considered "complex"tables. Additional information can be found here: http://www.w3.org/WAI/tutorials/tables/ ; note that the examples show ID tags added to the markup, but the examples are for small tables. This may not be functionally practical for large, complex tables. Some tables may not be practically accessible for use with assistive technology. Source: http://www.buyaccessible.gov/content/quick-reference-guide#1194.22

---

 

1194.22 (g) Row and column headers shall be identified for data tables.

What does this requirement mean? Terms and Definitions: data tables - tables used to represent tabular information. Assumptions: Assume this requirement does not apply to tables used strictly for layout purposes, and assume that informed humans can reasonably consistently judge whether a table is used strictly for layout. How can I tell if this requirement is met? Identify all uses of a data table. Establish that the table is a data table which needs column and / or row headers for understanding its contents.

1. Inspect web content source to help identify appropriate data table headers. Some tips for inspection of HTML to help identify appropriate identification of data table headers:
   1. Column headers: the first data row of the table is composed of <th> elements instead of <td> elements.
   2. Row headers: the first cell of each data row is a element instead of a <td> element.Note: Tables that are used strictly for layout should avoid this markup.
   3. Apply AT to make sure row and column headers are identified. Note the use of AT as a measurement method is limited by the adequacy of algorithms and heuristic methods of the specific AT tool used. It can be used to identify problems with specific AT-E&IT interoperability but it cannot predict results with other AT or with other versions of the same AT, OS, application or accessibility architecture. AT should include the full range e.g. screen readers, screen magnifiers, alternate input devices, etc
   Note: Satisfying this requirement supports interoperability with assistive technology, such as screen readers and magnifiers, which must be able to interpret data tables. Where can I get additional information?
   1. Guide to the Section 508 Standards for Electronic and Information Technology, Web-based Intranet and Internet Information and Applications (1194.22), Updated: June 21, 2001, http://www.access-board.gov/sec508/guide/1194.22.htm#(g)
   2. The W3C WAI Web Content Accessibility Guidelines 1.0 Checkpoint 5.1 provides further guidance and techniques for this requirement athttp://www.w3.org/TR/WCAG10/#tech-table-headers
   3. W3C WAI User Agent Accessibility Guidelines 1.0 techniques for browsers, etc. to handle HTML tables: http://www.w3.org/TR/UAAG10-TECHS/topics.html#table-techniques
   4. The W3C WAI maintains a listing of various tool and services available for evaluation and repair of web pages for web content accessibility, athttp://www.w3.org/WAI/ER/existingtools.html
   5. IBM Web accessibility checklist version 5.1, checkpoint 1.3e http://www-03.ibm.com/able/guidelines/web/accessweb.html

---

 

1194.22 (h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

What does this requirement mean? Terms and Definitions:  data tables - tables used to represent tabular information. Assumptions: Assume that informed humans can reasonably consistently judge whether the markup adequately reflects the table row and column headers. How can I tell if this requirement is met? Identify all uses of a data table that have two or more logical levels.

1. Inspect web content source to help identify appropriate multi-level data table headers. Are row and column headers associated with each data cell?
   1. Inspect the HTML find appropriate identification of multi-level data table headers by looking for various combinations of the <thead>, <col>, <colgroup>, and <th> elements, and "axis", "id", "scope", and "headers" attributes.
   Note: Tables that are used strictly for layout should avoid this markup.
2. Apply AT to make sure row and column headers are identified. Note the use of AT as a measurement method is limited by the adequacy of algorithms and heuristic methods of the specific AT tool used. It can be used to identify problems with specific AT-E&IT interoperability but it cannot predict results with other AT or with other versions of the same AT, OS, application or accessibility architecture. AT should include the full range e.g. screen readers, screen magnifiers, alternate input devices, etc

Note: Satisfying this requirement supports interoperability with assistive technology, such as screen readers and magnifiers, which must be able to interpret data tables. Where can I get additional information?

1. Guide to the Section 508 Standards for Electronic and Information Technology, Web-based Intranet and Internet Information and Applications (1194.22), Updated: June 21, 2001, http://www.access-board.gov/sec508/guide/1194.22.htm#(h)
2. The W3C WAI Web Content Accessibility Guidelines 1.0 Checkpoint 5.2 provides further guidance and techniques for this requirement athttp://www.w3.org/TR/WCAG10/#tech-table-structure
3. W3C WAI User Agent Accessibility Guidelines 1.0 techniques for browsers, etc. to handle HTML tables: http://www.w3.org/TR/UAAG10-TECHS/topics.html#table-techniques
4. The W3C WAI maintains a listing of various tool and services available for evaluation and repair of web pages for web content accessibility, athttp://www.w3.org/WAI/ER/existingtools.html
5. IBM Web accessibility checklist version 5.1, checkpoint 1.3e http://www-03.ibm.com/able/guidelines/web/accessweb.html

What's your standard? Accessibility In Mind has you covered for Section 508, PDF/UA, WCAG 2.0, HHS

Ensuring Indemnity With Documentation

Accessibility In Mind offers extensive accessibility reporting supporting all recognized standards, guaranteeing compliance. Whatever your specific requirements may be, AIM can remediate your documents to comply.

• Section 508: Section 508 was originally added as an amendment to the Rehabilitation Act of 1973 in 1986. It requires  Federal agencies to make their electronic and information technology accessible to people with disabilities. The regulations are broad in nature and are interpreted differently by different agencies. AIM can provide Section 508 specific reports certifying compliance.
• PDF/UA: PDF/UA (“Universal Accessibility”) specification, or ISO 14289, was published by the International Organization for Standardization (ISO) in August, 2014. PDF/UA requires Tagged PDF (ISO 32000-1, 14.8), and adds a variety of qualitative requirements, especially regarding semantic correctness of the tags employed. It is the first fully accessible standard ISO has ever published. AIM can provide PDF/UA specific reports certifying compliance.
• WCAG 2.0: The current version,  was published in December 2008 and became an ISO standard, ISO/IEC 40500:2012 in October 2012.It consists of 14 guidelines which are general principles of accessible design, primarily for websites, but applicable to PDF accessibility. AIM can provide WCAG specific reports certifying compliance.
• HHS: The United States Department of Health and Human Services (HHS) maintains a checklist defining their interpretation of Section 508, providing specific guidance on compliant PDF structure. AIM can provide HHS-specific reports certifying compliance.

Every remediated document is delivered with time-stamped Adobe Acrobat Pro 11 full accessibility reports, and NetCentric CommonLook reports are available for all accessibility standards. These reports prove due diligence in compliance with the most stringent requirements, and ensure indemnity from any legal challenges to document compliance.

Accessibility In Mind gives you one less thing to worry about- contact us for more information.

Is there any such thing as "Certification" for section 508 compliance?

Yes, Virginia, there is.

 AIM, formerly Electronic Document Compliance Services, is pleased to announce the availability of certificates of compliance for Section 508, PDF/UA, HHS, and WCAG 2.0. AIM can evaluate and certify compliance of any PDF, providing time-stamped accessibility reports, your insurance against any and all claims of non-compliance, guaranteed.

Contact us for a no-obligation evaluation of your documents.

EDCS To Become Accessibility In Mind

Electronic Document Compliance Services, a recognized leader in Section 508 and PDF/UA remediation services, has announced their new company name, Accessibility In Mind. 

From the company's press release:

Our mission remains constant, accessibility for all, and our singular service is document conversion and remediation- a one-stop solution to your compliance needs. Accessibility In Mind's federally certified compliance specialists complete all remediation, following industry best practices and using the latest technology, with comprehensive standards support of WCAG 2.0, PDF/UA, HHS as well as Section 508.

Health Insurance Document Specialists

We are experienced in remediation for all types of health insurance provider documents- ANOC, EOC, SOB, etc., with rapid turnaround. Complete documentation of remediation performed and compliance test reports are part of every deliverable.

Contact Accessibility In Mind and see how we can take care of your compliance needs.

Aiming to exceed your expectations: http://accessibilityinmind.com/

The "Refresh":US Access Board Proposes Updated ICT Accessibility Requirements

The US access Board has released for public comment a proposed rule updating accessibility requirements for information and communication technology (ICT) in the federal sector covered by Section 508 of the Rehabilitation Act. The rule also would jointly update guidelines for telecommunications equipment subject to Section 255 of the Communications Act.

The updated proposal is "...responsive to fundamental changes, innovations, and trends in the industry, such as the widespread convergence of technologies..." according to the summary, and should help all in the industry interpret Section 508 with fresh guidance.

The proposed rule includes significant changes that would:

•  incorporate the WCAG 2.0 and apply associated success criteria to websites as well as to offline electronic documents and software; 
• require real-time text functionality (text that is transmitted character by character as it is being typed) for products providing real-time, two-way voice communication; 
• specify the types of non-public facing electronic content covered; 
• and further detail the required compatibility of covered technologies, including operating systems, software development toolkits, and software applications with assistive technology.

Specific to PDF, the proposed rules address "accessible PDF files (ISO 14289-1, Document management applications — Electronic document file format enhancement for accessibility — Part 1: Use of ISO 32000-1 (PDF/UA-1))

More information is here, and an overview of the refresh can be read here.